US/UK Tax and Wealth Planning

The UK left the EU on 31 January 2020. A transition period, during which EU laws continue to apply in the UK, is due to end on 31 December 2020. The UK/EU Withdrawal Agreement sets out transitional arrangements and negotiations for the future UK/EU relationship are ongoing.

Our clients with business interests and personal wealth in the US and the UK are required to navigate two complex and very different tax systems. Successful wealth planning for such clients requires the lead advisor to be "ambidextrous" in that they understand the tax treatment of a proposed transaction in both countries simultaneously. This is what makes Mishcon de Reya different. Whereas we do not give US advice, we have a team of specialist UK tax and trust lawyers with a deep understanding of US tax and trust concepts. Our independence allows us to work with either the client's own US tax counsel or procure the best US advice from our extensive network of US law firms and tax advisory firms to provide integrated US/UK solutions.

We enable our clients to comply with their UK and US tax reporting and payment obligations while maximising available tax reliefs, and advise on all areas of personal tax and trust and estate planning including on the formation, administration, taxation and governance of tax and wealth planning structures.

We travel to the US regularly, coordinating and working closely with our clients' advisors there, including US tax advisors, bankers and family offices.

Key Areas of Expertise

We advise UK resident US settlors and/or beneficiaries of US trusts on managing their potential exposure to double taxation. We also have experience of mitigating the risk of double taxation on income from US LLCs and S Corps.

We regularly advise on the use of excluded property trusts and protected settlements for UK resident, US citizens as well as on the use and creation of life insurance trusts for US citizens who are living in the UK.

Family Limited Partnerships can be especially important for US citizens where UK inheritance tax considerations preclude the use of trusts.

We assist US citizens with their pre-UK immigration tax planning.

We deal with all aspects of inheritance tax planning but have particular expertise in advising US based British expats on managing their potential UK inheritance tax exposure.

We advise UK resident US citizens on their ability to use the EU Succession Regulation to exercise their rights to avoid “forced heirship” rules on European  assets.

We have the expertise to draft trusts that simultaneously qualify as foreign grantor trusts for US purposes and protected trusts for UK income tax purposes.

We can assist with the establishing of dual-qualified charitable entities.

We regularly draft integrated Wills and revocable trusts for US/UK citizens and have extensive experience in cross border estate administration and probate.  We regularly assist US lawyers to apply for UK Grants of Probate.

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